State v. Linscott
520 A.2d 1067 (1987)
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Rule of Law:
An accomplice to a primary crime is criminally liable for a secondary crime committed by the principal if the commission of the secondary crime was a reasonably foreseeable consequence of the accomplice's participation in the primary crime, regardless of whether the accomplice possessed the specific culpable mental state required for the secondary crime.
Facts:
- William Linscott, Phillip Willey, and Jeffrey Colby picked up Joel Fuller, who was in possession of a sawed-off shotgun.
- The group then acquired 12-gauge shotgun shells for Fuller's weapon.
- Fuller proposed a plan to rob Norman Grenier, a reputed drug dealer, which Linscott agreed to, expecting a $10,000 share of the proceeds.
- Linscott drove the group to Grenier's rural home.
- Linscott, armed with knives, and Fuller, armed with the shotgun, approached the house to commit the robbery while the others waited in the car.
- According to their plan, Linscott broke the living room window with his body to initiate the robbery.
- Immediately after Linscott broke the window, Fuller fired a shot through it, killing Grenier.
- Fuller stole approximately $1,300 from Grenier and later gave Linscott $500.
Procedural Posture:
- William Linscott was indicted on one count of murder and one count of robbery.
- Following a jury-waived trial in the Superior Court, Waldo County, the trial justice found Linscott guilty of robbery.
- The trial justice also found Linscott guilty of murder on a theory of accomplice liability.
- The trial court specifically found that while Linscott intended to commit robbery, he did not intend to kill the victim, but that the murder was a reasonably foreseeable consequence of the robbery.
- Linscott (appellant) appealed his murder conviction to the Supreme Judicial Court of Maine, arguing the accomplice liability statute was unconstitutional.
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Issue:
Does Maine's accomplice liability statute violate the Due Process Clause by permitting a murder conviction for an accomplice who did not intend to cause death, based on the murder being a 'reasonably foreseeable consequence' of the underlying felony he intended to aid?
Opinions:
Majority - Scolnik, Justice.
No, the accomplice liability statute does not violate the Due Process Clause. The 'foreseeable consequence' rule allows an accomplice to be convicted of a secondary crime if it was a reasonably foreseeable outcome of the primary crime the accomplice intended to promote, even without proof that the accomplice possessed the specific subjective intent for the secondary crime. The court reasoned that liability for a secondary crime is established by a two-part showing: (a) the accomplice intended to promote the primary crime (robbery), and (b) the commission of the secondary crime (murder) was a foreseeable consequence of participation in the primary crime. This objective standard is rooted in common law and is consistent with other Maine statutes, such as those for felony murder and depraved indifference murder, which do not require a subjective culpable mental state for the resulting death. Therefore, finding a defendant guilty of murder under this theory, when they participated in an armed robbery where death was a foreseeable outcome, is not fundamentally unfair and does not violate due process.
Analysis:
This decision affirms the constitutionality of the 'foreseeable consequence' rule in Maine's accomplice liability doctrine. It solidifies that an accomplice's culpability can be established through an objective standard (what a reasonable person would foresee) rather than a subjective one (what the defendant actually intended). This significantly lowers the prosecution's burden, as they do not need to prove the accomplice shared the principal's specific intent for all resulting crimes. The ruling aligns accomplice liability with felony murder principles, holding participants in dangerous felonies responsible for deaths that occur during their commission, thereby broadening the scope of liability for individuals who aid in criminal enterprises.
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